Licensing of software not taxable in India as royalty

CIT Vs Microsoft Corporation (Delhi High Court)

The amounts paid by resident Indian end-users/distributors to non­resident computer software manufacturers/suppliers, as consideration for the resale/use of the computer software through EULAs/distribution agreements, is not the payment of royalty for the use of copyright in the computer software, and that the same does not give rise to any income taxable in India

Facts-

The appellant-Reve

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